The Heat Network [Metering and Billing] Regulations 2014
came into force in December of last year. Their overall purpose is to reduce the
amount of energy individuals and business use thereby reducing costs and the
amount of energy consumed across the country. The way they do this is by
requiring heat suppliers (those that supply and charge for heat, cooling or hot
water to an end user) to provide information to the National Measurement Office
(NMO) regarding their heat network. Clearly, the definition of heat supplier
will cover landlords who provide communal heating and this information must be
submitted to the NMO before 31 December 2015 and from then on, at least every
four years. The two main issues tackled by the Regulations relate to billing
and meters.
Billing
From 19 December 2014, there is an obligation on
landlords relating to actual use billing. This aims to enhance awareness and
transparency by requiring heat suppliers to bill based on actual consumption
where meters or heat cost allocators are installed. This requirement need only
be met where the cost of providing such detailed bills would not exceed £70 per
annum per end user. Bills should contain current energy prices, details of
total consumption (compared to the previous year if possible) and general
information on how to improve energy efficiency.
There is a duty to bill on actual meter readings even if
final customer point meters are not installed (as a result of a feasibility
study on retrofitting to existing unmetered schemes), in this case it is the
bulk meter readings that should be used.
Meters
There are 2 variations of meter installation requirements
that come into force on 31 December 2016.
1. The installation of meters is to
measure the use of heating, cooling or hot water by each end user/final
customer. The meters must be installed only if it is cost effective and
technically feasible to do so.
2. If it is not cost effective or
technically feasible to install meters – If the heat supplier supplies both
heating and hot water, they would have to install heat cost allocators, thermostatic
radiator valves at each radiator and a hot water meter. Again, this is only
required if it is cost effective and technically feasible to do so.
Cost effectiveness in terms of the Regulations is where
the projected energy savings to the final customer over the 10 year period
subsequent to installation, is greater than the estimated reasonable costs of
installing the meters.
The meters must accurately measure, memorise and display
the consumption of hot water by each end user. If meters are installed,
temperature control devices must also be installed to enable the control of
consumption by the tenant but only for heating and cooling – not hot water.
It should be noted for the further that the Regulations
require the installation of meters when an existing meter is replaced, a new
connection is made in a new building or a building undergoes a major
renovation.
These Regulations have not been very well publicised but
their impact on landlords could be significant. Those that, on determining that
it would be cost effective and feasible to install meters, fail to do so, could
be found criminally liable and fined.